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    <title>2020 (8) TMI 176 - ITAT BANGALORE</title>
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    <description>Receipts from the sale of carbon credits were treated as capital receipts arising from environmental entitlements, not as income generated from the assessee&#039;s business operations, so they were held not chargeable to tax and outside deduction under section 80IA. On the section 14A read with Rule 8D issue, the earlier approach based on dominant purpose of investment could not be sustained because that test is irrelevant, but the factual question of availability of own funds and other relevant circumstances had not been examined. The disallowance was therefore remanded for de novo consideration.</description>
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      <title>2020 (8) TMI 176 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=397233</link>
      <description>Receipts from the sale of carbon credits were treated as capital receipts arising from environmental entitlements, not as income generated from the assessee&#039;s business operations, so they were held not chargeable to tax and outside deduction under section 80IA. On the section 14A read with Rule 8D issue, the earlier approach based on dominant purpose of investment could not be sustained because that test is irrelevant, but the factual question of availability of own funds and other relevant circumstances had not been examined. The disallowance was therefore remanded for de novo consideration.</description>
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      <pubDate>Fri, 07 Aug 2020 00:00:00 +0530</pubDate>
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